Mountain Creek Lake and Hensley Field - Assessment Plan

Draft Available for Public Comment (May 7, 2021)
NATURAL RESOURCE DAMAGE ASSESSMENT

PLAN
Mountain Creek Lake: Naval Air Station Dallas

and Naval Weapons Industrial Reserve Plant
DRAFT
May 2021
Prepared by:
Texas Parks and Wildlife Department

Texas Commission on Environmental Quality
Texas General Land Office
TABLE OF CONTENTS
1. INTRODUCTION AND BACKGROUND INFORMATION ........................................................ 1
1.1 Purpose of the Assessment Plan .......................................................................................... 2
1.2 Authority to Conduct a NRDAR ............................................................................................ 3
1.3 NRDAR Process Overview .................................................................................................... 4
1.4 Invitation to Potentially Responsible Parties for Cooperative Assessment ........................... 5
1.5 Coordination with Other Activities ...................................................................................... 5
1.6 Public Participation ............................................................................................................. 6
1.7 Assessment Timeline ........................................................................................................... 6
2. DESCRIPTION OF THE ASSESSMENT AREA ........................................................................ 7
2.1 Facility History ..................................................................................................................... 7
2.1.1 Facility Development ............................................................................................................................. 7
2.1.2 Summary of Releases ............................................................................................................................. 8
2.1.3 Confirmation of Exposure ...................................................................................................................... 9
2.2 Affected Natural Resources ............................................................................................... 10

2.2.1 Surface Water Resources ..................................................................................................................... 10
2.2.2 Groundwater Resources ...................................................................................................................... 11
2.2.3 Air and Geologic Resources ................................................................................................................. 12
2.2.4 Biological Resources ............................................................................................................................ 12
2.2.5 Human/Recreational Use..................................................................................................................... 13
3. INJURY ASSESSMENT AND PATHWAY DETERMINATION APPROACH .............................. 13

3.1 Temporal ........................................................................................................................... 13
3.2 Use of Available Data ........................................................................................................ 14
3.3 Intent to Perform a Type B Assessment ............................................................................. 14
3.4 Pathway Determination .................................................................................................... 15
4. INJURY ASSESSMENT...................................................................................................... 17
4.1 Injury Assessment for Aquatic Resources ........................................................................... 17
4.1.1 Aquatic Resource Evaluation ............................................................................................................... 17
4.2 Injury Assessment for Human/Recreational Use ................................................................ 18

5. APPROACH TO DAMAGE DETERMINATION .................................................................... 19
5.1 Aquatic Resource Damage Determination ......................................................................... 19
5.2 Human/Recreational Use Damage Determination ............................................................. 19
6. PRELIMINARY ASSESSMENT OF DAMAGES ..................................................................... 19
7. QUALITY ASSURANCE ..................................................................................................... 19
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8. REFERENCES ................................................................................................................... 21
APPENDICES
APPENDIX A – SITE HISTORY............................................................................................................... 30
APPENDIX B – SUMMARY OF RELEASES .............................................................................................. 37
APPENDIX C – CHEMICALS OF POTENTIAL CONCERN .......................................................................... 40
APPENDIX D – RARE, THREATENED, AND ENDANGERED SPECIES ........................................................ 45
FIGURES
Figure 1.1 Map of the Mountain Creek Lake system, Dallas Naval Air Station (NAS Dallas) and Naval
Weapons Industrial Reserve Plant (NWIRP). ................................................................................ 2
Figure 1.2 Phases of the Natural Resource Damage Assessment Process. ............................................. 5
Figure 2.1 Cottonwood Creek and Mountain Creek Lake Watersheds. ................................................ 11
Figure 3.1 Conceptual model describing the fate of releases from the Facility. ................................... 16
TABLES
Table 1. Site History. .......................................................................................................................... 31
Table 2. NAS and NWIRP Hazardous Waste Generating Activities/Sources. ........................................ 38
Table 3. List of chemicals of potential concern (COPC) and basic information describing the chemical.
.................................................................................................................................................. 41
Table 4. Rare, threatened, endangered species potentially present in the Assessment Area. ............. 46
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LIST OF ACRONYMS AND ABBREVIATIONS
ABMCIC American Brownfields Mountain Creek Industrial Center, LLC

AOC Area of Concern
APAR Affected Property Assessment Report
ATSDR Agency for Toxic Substances and Disease Registry
CDD Chlorinated dibenzo-p-dioxin
BRAC Base Realignment and Closure
CAO Corrective Action Order
CDF Chlorinated dibenzofuran
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
COC Contaminant of Concern
COPC Chemical of Potential Concern
DGIC Dallas Global Industrial Center
DOD Department of Defense
DOI United States Department of the Interior
DOJ United States Department of Justice
DSAY Discounted Service Acre-Year
EPA United States Environmental Protection Agency
FACILITY Naval Air Station and Naval Weapons Industrial Reserve Plant Dallas
GLO Texas General Land Office
GOCO Government-owned, Contractor-operated
HEA Habitat Equivalency Analysis
MNR Monitored Natural Recovery
NAS Naval Air Station
NAVY United States Department of the Navy
NCP National Contingency Plan
NOAA National Oceanic and Atmospheric Administration
NRDAR Natural Resource Damage Assessment and Restoration
NWIRP Naval Weapons Industrial Reserve Plant
PAHs Polycyclic Aromatic Hydrocarbons
PAS Preassessment Screen
PCBs Polychlorinated Biphenyls
PCL Protective Concentration Level
PCLE Protective Concentration Level Exceedance
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PR/VSI Preliminary Review/Visual Site Inspection

PRP Potentially Responsible Party
QA Quality Assurance
QAP Quality Assurance Plan
QC Quality Control
RAP Response Action Plan
RAER Response Action Effectiveness Report
RCDP Restoration and Compensation Determination Plan
RCRA Resource Conservation and Recovery Act
RFI Resource Conservation and Recovery Act Facility Investigation
SLERA Screening Level Ecological Risk Assessment
SRS Substance Registry Service
SWMU Solid Waste Management Unit
TAC Texas Administrative Code
TCEQ Texas Commission on Environmental Quality
TDH Texas Department of Health
TDSHS Texas Department of State Health Services
TMDL Total Maximum Daily Load
TPWD Texas Parks and Wildlife Department
TXU Texas Utilities
USACE United States Army Corps of Engineers
USGS United States Geological Survey
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1. INTRODUCTION AND BACKGROUND INFORMATION

The Texas Commission on Environmental Quality (TCEQ), the Texas Parks and Wildlife
Department (TPWD), and the Texas General Land Office (GLO) (collectively, the Trustees) are
designated as Trustees for natural resources and may pursue claims for natural resource
damages in Texas under section 107(f) of the Comprehensive Environmental Response,
Compensation, and Liability Act as amended (CERCLA) (42 U.S.C. § 9607(f)). CERCLA regulations
in 43 CFR Part 11 establish an administrative process for conducting a natural resource damage
assessment (NRDA) to determine the injury, quantify the damage, and assess alternative
remedies to restore the injured natural resources. While following these regulations is optional,
Trustees who conduct an assessment consistent with these regulations are entitled by law to a
rebuttable presumption in any subsequent NRDA litigation. (See 42 U.S.C. § 9607(f)(2)(C)).
Pursuant to 43 CFR Part 11, the Trustees completed a Preassessment Screen and Determination
(PAS) in July 2000 finding that sufficient information was available to proceed with a natural
resource damage assessment and restoration (NRDAR). Moving forward, the Trustees prepared
this Assessment Plan to serve as the guiding document for damage assessment activities.
The U.S. Department of the Navy (Navy) formerly owned and/or operated the Naval Weapons
Industrial Reserve Plant (NWIRP) and Naval Air Station Dallas (NAS Dallas)(collectively, the
Facility) located along the northwest shore of Mountain Creek Lake, in the City of Dallas, Dallas
County, Texas (Figure 1.1). As stated in the PAS, the Trustees evaluated existing data and
determined that the Navy released hazardous substances from the Facility into the
environment, potentially injuring multiple natural resources. The injury assessment (Section 4)
will evaluate the areas impacted by the release of hazardous substances at or from the Facility,
including but not limited to the Mountain Creek Lake system and the associated nearshore zone
(Assessment Area). For the purposes of this assessment, the Mountain Creek Lake system
includes Cottonwood Bay and the diversion channel connecting the two waterbodies.
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Figure 1.1 Map of the Mountain Creek Lake system, Dallas Naval Air Station (NAS Dallas) and Naval
Weapons Industrial Reserve Plant (NWIRP).
1.1 Purpose of the Assessment Plan

The purpose of this Assessment Plan is to outline the proposed approach for determining and
quantifying natural resource injuries and damages associated with those injuries. Injury means
a measurable adverse change, either long- or short-term, in the chemical or physical quality or
the viability of a natural resource resulting either directly or indirectly from exposure to a
discharge of oil or release of a hazardous substance. (43 CFR § 11.14(v)). Damages is a legal
term for the amount of money sought in a claim made by Trustees as compensation for injury,
destruction, or loss of natural resources; damages include the costs of assessing injuries as well
as the costs of restoration. (42 U.S.C. §§ 9601(6), 9607(a)(4)(C)). By developing an Assessment
Plan, the Trustees ensure that the NRDAR will be completed at a reasonable cost relative to the
magnitude of the damages (43 CFR § 11.13(c)). The Trustees also intend for this Plan to
communicate proposed assessment methodologies to the public and the potentially
responsible party (PRP) so that these groups can productively participate in the assessment
process.
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This Assessment Plan was based on the Trustees’ current understanding of relevant studies and
identifies other processes (e.g., data review and analysis) that may be needed to quantify injury
to natural resources and their associated services. Studies and other processes described in this
Assessment Plan do not limit the possibility of additional work, nor does the Assessment Plan
guarantee that the included efforts will be completed. The Assessment Plan provides an initial
prioritization of efforts the Trustees will take during the Injury Assessment process.
1.2 Authority to Conduct a NRDAR

The NRDAR is being conducted jointly by the Trustees pursuant to their respective authorities
and responsibilities as Texas natural resource Trustees. The Trustees have each been
designated as a natural resource trustee pursuant to Section 107(f)(2)(B) of CERCLA, 42 U.S.C.
§ 9607(f)(2)(B); Section 311 of the Clean Water Act (CWA), 33 U.S.C. § 1321; and Subpart G of
the National Contingency Plan (NCP), 40 C.F.R. §§ 300.600 - 300.615. Under these authorities,
the Trustees act on behalf of the public to seek damages for the injury, loss, or destruction of
natural resources belonging to, managed by, controlled by, or appertaining to the State, that
resulted from releases of hazardous substances. This includes implementing a NRDAR to
evaluate the injury, loss, or destruction of natural resources and their services due to releases
of hazardous substances.
By order of Governor Clements on July 29, 1988, the Texas Water Commission (predecessor
agency to the TCEQ) was designated as the state’s natural resource trustee, pursuant to
CERCLA, as amended by the Superfund Amendments and Reauthorization Act, which provided
that “the Governor of each State shall designate State officials . . .” and that “(s)uch State
officials shall assess damages to natural resources . . . for those natural resources under their
trusteeship.” (CERCLA Section 107(f)(2)(B)). Governor Clements designated TPWD as a co-
trustee in 1990, as the state agency with primary responsibility for fish and wildlife resources
under state law. GLO was designated as a third co-trustee for purposes of NRDA by Governor
Richards in 1991.
Relevant regulations include Subpart G of the NCP (40 CFR §§ 300.600 through 300.615) and
U.S. Department of the Interior’s (DOI’s) NRDAR Regulations at 43 CFR Part 11 (DOI NRDAR
Regulations), which provide guidance for the NRDAR process under CERCLA. In addition, the
Texas Water Code provides for recovery of costs to determine impacts on the environment
from a spill or discharge and to restore land and aquatic resources held in trust or owned by the
State (Tex. Water Code § 26.265). Trustees are authorized to act on behalf of the public under
state and/or federal law to assess and recover natural resource damages and to plan and
implement actions to restore natural resources and their services that are injured or lost as the
result of hazardous substances released at or from the Facility.
Consistent with the DOI NRDAR Regulations, the Trustees’ decision to proceed with this
assessment is based on the results of a PAS. The PAS concluded that there is a viable PRP and all
preassessment screening criteria have been met. (See 43 CFR § 11.23(e)). Accordingly, the
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Trustees, acting on behalf of the public, found sufficient cause to proceed with a NRDAR.
Specifically, the Trustees determined that:
• A discharge of oil or a release of a hazardous substance occurred;

• Natural resources for which the Trustees may assert trusteeship under CERCLA have
been, or are likely to have been, adversely affected by the release;
• The quantity and concentration of the discharged oil or released hazardous
substance is sufficient to potentially cause injury to natural resources;
• Data sufficient to pursue an assessment are readily available or likely to be obtained
at a reasonable cost; and
• Response actions carried out, or planned, do not or will not sufficiently remedy
injury to natural resources without further action.
1.3 NRDAR Process Overview

The goal of the NRDAR process is to replace, restore, rehabilitate, or acquire the equivalent of
injured natural resources and their services lost due to the release of hazardous substances. As
specified in the DOI NRDAR Regulations (43 CFR Part 11), the NRDAR process includes three
phases (Figure 1.2):
• Preassessment,
• Assessment Plan, and
• Post-Assessment.
To date, as noted above, the Trustees have completed the Preassessment Phase. The Trustees
are now undertaking the Assessment Plan Phase, which includes the following (see 43 CFR
§§ 11.30 - 11.38):
• Injury determination,
• Quantification of injury, and
• Damage determination.
The final step of the Assessment Plan Phase may include the development of a Restoration and
Compensation Determination Plan (RCDP), which would review restoration alternatives for
restoring injured or lost natural resources and their services (see 43 CFR §§ 11.81, 11.93). Once
the Assessment Plan Phase is complete, the Trustees will begin the Post-Assessment Phase. In
the Post-Assessment Phase, the Trustees may develop a Report of Assessment, which contains
the results of the assessment and RCDP, including Trustee responses to comments received on
the drafts of the Assessment Plan and RCDP (see 43 CFR § 11.90). In addition, during the Post-
Assessment Phase, a draft Restoration Plan that documents the restoration project(s) will be
prepared and made available to the public for comment. The public will have an opportunity to
guide the assessment and restoration activities by providing comments on the draft
Assessment Plan, the draft RCDP, and the draft Restoration Plan. Once the Restoration Plan has
been finalized, restoration will be implemented.
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Figure 1.2 Phases of the Natural Resource Damage Assessment Process.
Each of the steps to be followed in assessing injury and damages is discussed in greater detail in
the sections and chapters that follow.
1.4 Invitation to Potentially Responsible Parties for Cooperative Assessment

At the time of the Preassessment Screen and Determination, the Trustees examined
information about the Facility in relation to Section 107(a) of CERCLA, 42 U.S.C. § 9607(a), to
determine the PRP(s). Parties liable under the statute include current owners and operators of
a facility and owners and operators of a facility at the time of a release of hazardous
substances. Facility data indicated that the principle contamination in the Assessment Area
occurred while the Navy or its contractors were owners and/or operators.
Following completion of the PAS, the Trustees sent a Notice of Intent and an Invitation to
Participate in a Cooperative NRDAR to the PRPs, including the Navy, Department of Defense
(DOD), Air Force, Army, Air National Guard, City of Dallas, Texas Utilities (TXU), Northrop
Grumman Industries, and American Brownfields Mountain Creek Industrial Center, LLC
(ABMCIC; Pitts 2000; Gregory 2016a; Gregory 2016b). The PRPs did not agree to participate in a
cooperative NRDAR.
1.5 Coordination with Other Activities

Consistent with 43 CFR § 11.31(a)(3)), Texas recognizes the benefit of coordinating assessment
activities associated with sites that may have significant contaminants of concern. To that end,
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30 Tex. Admin. Code § 7.124 (2001) describes a Memorandum of Understanding that seeks to
facilitate interactions between TCEQ and state and federal Trustees regarding ecological risk
assessments and ecological service analyses. Integration of Trustee considerations into
remedial decisions may resolve certain natural resource damages liability or decrease the cost
of assessment activities.
The Trustees have participated in the remedial process for the Facility since the late 1990s,
providing written and verbal comments on proposed actions. Trustee assessment activities
discussed in this Plan make use of existing data generated through the remedial process as well
as other research efforts.
1.6 Public Participation

The Trustees are seeking feedback on this draft Assessment Plan. To facilitate public
participation, the Trustees are making this Plan available to the public and PRP to review and
provide feedback on the proposed approach and studies. Public notice soliciting comments on
this Plan will be posted on TPWD’s website and published in the Texas Register. The 30-day
public comment period for this Assessment Plan will begin on date of publication of notice in
the Texas Register. All written public comments must be submitted within 30 days from the
date of publication of notice in the Texas Register. These comments will help the Trustees plan
and conduct an assessment that is scientifically valid, cost-effective, and that incorporates a
broad array of perspectives. To that end, the Trustees request that you carefully consider this
Assessment Plan and provide any comments you may have in writing to:
Michael Tennant
Texas Parks and Wildlife Department
Natural Resource Damage Assessment Team
4200 Smith School Road
Austin, TX 78744
Email: Michael.Tennant@TPWD.Texas.Gov
The Trustees will consider all timely public comments and input on the Assessment Plan. The
Trustees’ responses to public comments will be available in the Report of Assessment. Based on
the public’s comments or other information, the Trustees may modify the Assessment Plan at
any time. Any substantive modifications will be made available for review by the public,
including the PRP.
1.7 Assessment Timeline

The activities described in this plan are expected to take less than two years to complete. If new
information becomes available as this assessment progresses, and additional study is deemed
warranted, updates to this plan and the timeline will be made publicly available.
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2. DESCRIPTION OF THE ASSESSMENT AREA

According to the DOI NRDAR Regulations, natural resources for which damages may be sought
include: land, fish, wildlife, biota, air, water, groundwater, drinking water supplies, and other
such resources belonging to, managed by, held in trust by, appertaining to, or otherwise
controlled by the United States, any State or local government, any foreign government, any
Indian tribe, or, if such resources are subject to a trust restriction on alienation, any member of
an Indian tribe (42 U.S.C. § 9601(16)). Additionally, damages may be determined based on
injuries that are reasonably unavoidable as a result of response actions taken (43 CFR
§ 11.15(a)(1)). The DOI NRDAR Regulations group these natural resources into five categories:
surface water, groundwater, air, geologic, and biological (43 CFR § 11.62). The Assessment Area
is defined in the DOI NRDAR Regulations as:
The area or areas within which natural resources have been affected directly or
indirectly by the discharge of oil or release of a hazardous substance and that serves
as the geographic basis for the injury assessment (43 CFR § 11.14(c)).
The Assessment Area includes, but is not limited to, the Mountain Creek Lake system and the
associated nearshore zone (Figure 1.1).
2.1 Facility History

The Assessment Area has been affected by activities associated with the Facility. The NWIRP
and NAS Dallas properties adjoin each other and border the Mountain Creek Lake system
(Figure 1.1). Although both properties were used by the Navy, they were managed separately
and have different site histories (Appendix A) that resulted in releases into the Mountain Creek
Lake system (Appendix B).
2.1.1 Facility Development

NAS Dallas, named Hensley Field at the time, was established in August 1929 by the City of
Dallas, leased to the U.S. Army as a training field for reserve pilots of the U.S. Army Air Corps
(Leatherwood 1991) and expanded several times over the years. The largest expansion of NAS
Dallas occurred during World War II, reaching a maximum size of over 4,000 personnel in 1945.
The Navy began operations at the base in March 1941 and established a Naval Air Reserve Base
in May 1941 adjacent to Hensley Field. The initial mission of NAS Dallas, starting in January
1943, was to provide primary flight training for naval, marine, and coast guard cadets. During
World War II, the base also served as an engine repair station, flight test facility, and receiving
station for training aircraft manufactured at the North American Aviation Plant (Leatherwood
1991). Between 1949 and 1950, the base expanded again, extending the main northeast-
southwest runway on the fill that separated Cottonwood Bay from the main body of Mountain
Creek Lake.
NWIRP was constructed in 1941 as an aerospace manufacturing complex. It was a government-
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owned, contractor-operated (GOCO) facility that was used, in part, for designing, fabricating,
and testing prototype weapons and aerospace equipment and for pilot training. North
American Aviation, Inc., leased the site from 1941 to 1945, producing nearly 30,000 aircraft for
the Army, Air Force, and Navy. Following the war, the Navy gained stewardship of the
manufacturing complex and leased it to multiple entities, including: North American Aviation,
Texas Engineering and Manufacturing Company (TEMCO), Chance Vought Aircraft Corporation,
Ling-Temco-Vought, Northrop Grumman, and Vought Aircraft Industries.
Navy-related activities at the Facility eventually ceased and the properties were transferred to
new owners. The 1993 Base Realignment and Closure Commission slated NAS Dallas for closure,
and training for naval reservists ceased in 1993. In 1998, NAS Dallas was closed and returned to
the City of Dallas. In 2012, the United States sold NWIRP to ABMCIC, now known as Dallas
Global Industrial Center, LLC (DGIC, LLC).
Mountain Creek Lake adjoins the Navy properties and was developed during the same time
period as NAS Dallas and NWIRP. The lake was created in 1929 by impounding Mountain Creek.
It was designed as a cooling reservoir for a Dallas Power and Light Company electric power
plant. Twenty years later, in 1949, a diversion channel was constructed to allow flow from the
Cottonwood Creek drainage into Mountain Creek Lake (Figure 1.1).
2.1.2 Summary of Releases

The Facility has documented past releases of petroleum products, volatile organic compounds
(VOCs), polychlorinated biphenyls (PCBs), and metals. Appendix B contains the list of hazardous
substances released from the Facility.
Releases from the Facility occurred from various industrial and aircraft support operations,
production buildings, solid waste management units, and storage areas. A 2003 report
commissioned by the Navy stated that the largest single source of Navy contamination into the
Mountain Creek Lake system was the west lagoon at the Facility, which discharges into
Cottonwood Bay (Newfields 2003). The west lagoon received and discharged a variety of
industrial wastes and treated sanitary sewage for approximately 30 years from the 1940s to
1970s. Other sources of contamination from the Facility include the east lagoon and various
stormwater outfalls. VOC-contaminated groundwater beneath the Facility flows toward and
seeps into the Mountain Creek Lake system (Newfields 2003; Van Metre et al. 2003).
Historically, the Facility discharged water products and contaminated stormwater into the
Mountain Creek Lake system.
The Trustees anticipate focusing the NRDAR on direct and indirect injuries stemming from
exposure to released hazardous substances as defined in Section 101(14) of CERCLA. The
damage assessment may also focus on injuries associated with response actions. The Trustees
identified chemicals of potential concern (COPCs) in the preassessment phase. The COPCs that
the Trustees anticipate considering as part of the Assessment process are listed in Appendix C.
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The specific chemicals that the injury analysis will focus on will be chosen as part of the
assessment process.
2.1.3 Confirmation of Exposure

As required by 43 CFR § 11.37, the Trustees have confirmed that at least one of the natural
resources identified in the preassessment screen as potentially injured has been exposed to
hazardous substances. The preassessment screen identified several potentially injured natural
resources, including surface water, sediments, and benthic organisms. Surveys, field
investigations, and assessments conducted over the years indicate that releases from the
Facility entered the sediments and waters of the Mountain Creek Lake system and
bioaccumulated into fish tissues.
NAS Dallas began conducting a Resource Conservation and Recovery Act (RCRA) Facility
Assessment in the 1980s due to suspected releases from site operations. As part of the
assessment, contaminants released, the potential for contaminants to be released, and the
likelihood of transport of those contaminants was evaluated. Records related to this work can
be found in the Navy’s Administrative Record for NAS Dallas (Navy 2020b). Concurrent
investigations were also done at NWIRP starting in the 1980s (see references in Section 3.2 of
Radian International 1999). These investigations concluded there was contamination from
hazardous substances in the surrounding area’s surface waters, groundwater, soils, and
sediments.
In 1991, the DOD notified state and federal natural resource Trustees of a release of hazardous
substances associated with the Facility (Malone 1991).
As a result of the RCRA Facility Assessment, DOD, acting through the Southern Division Naval
Facilities Engineering Command, began research in cooperation with the United States
Geological Survey (USGS) to determine whether contaminants from the Facility migrated or
continued to migrate into the Mountain Creek Lake system. The USGS report indicates that
metals, PCBs, and VOCs from the Facility entered the sediments and waters of the Mountain
Creek Lake system (Van Metre et al. 2003).
High levels of PCBs in the sediments of the lake system bioaccumulated in fish tissues and led
the Texas Department of Health (TDH) to issue Aquatic Life Order Number 12, which banned
the possession and consumption of fish taken from the system (TDH 1996). At the time the
order was issued, fish tissue sampling indicated the presence of PCBs at concentrations
exceeding health assessment guidelines established by TDH. The fish possession ban in Aquatic
Life Order Number 12 demonstrates that natural resources, including surface water, sediments,
and benthic organisms, were exposed to a release of hazardous substances from the Facility.
Detailed information confirming the exposure of resources to hazardous substances being
assessed as part of the NRDAR are described in further detail as part of the remedial
investigations (ENSAFE 1999; Jones et al. 1997; Van Metre et al. 2003).
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2.2 Affected Natural Resources

The Assessment Area supports a variety of natural resources and services potentially affected
by hazardous substances released from the Facility, including surface waters, groundwater,
sediments, birds, fish, other biota, and human/recreational uses, including fishing. The
following paragraphs briefly summarize select features of the natural resources that the
Trustees are currently considering assessing for injury.
2.2.1 Surface Water Resources

The surface water resources in the Assessment Area include the water, suspended sediment,
and bed sediments. The contamination of these resources has both direct and indirect impacts
on the health of biological resources. For example, contaminated sediments can cause injury to
benthic invertebrate populations, which in turn can result in injuries to resident fish
populations that consume them as a source of food. Similarly, injury to invertebrates and/or
fish resulting from exposure to contaminated sediments and surface water can lead to injury in
local insectivorous (insect eating) or piscivorous (fish eating) bird populations. In addition,
contaminated sediments serve as a source of continuing releases of hazardous substances to
the water column.
Surface water resources provide a suite of ecological and human services. Ecological services
include, but are not limited to, habitat for trust species, including food, shelter, breeding areas,
and other factors essential to survival. Human services provided by surface water resources
include, but are not limited to, recreational fishing, boating, and canoeing.
The Mountain Creek Lake system (TCEQ Segment 0841A) is a tributary of the Lower West Fork
of the Trinity River. Today, Mountain Creek Lake is approximately 3.4 miles long and 1.2 miles
wide, with an average depth of 8.5 feet and a maximum depth of approximately 26 feet (TPWD
2016). Cottonwood Bay, another part of the Mountain Creek Lake system, is approximately 1
mile long by 0.1 miles wide. Mountain Creek Lake has a surface area of 2,696 acres and
reservoir storage capacity of 22,850 acre-feet at 457.0 feet conservation pool elevation (TWDB
2020). Mountain Creek Lake was created by damming Mountain Creek. Water flows towards
the east from Cottonwood Creek into Cottonwood Bay. Waters from the Bay are transported
through the diversion channel into the main body of Mountain Creek Lake. Waters in the
Mountain Creek Lake watershed flow northerly from Lake Joe Pool to Mountain Creek into
Mountain Creek Lake. Water flows out of Mountain Creek Lake to the north through a dam to
Mountain Creek (Figure 2.1).
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Figure 2.1 Cottonwood Creek and Mountain Creek Lake Watersheds (Newfields 2003).
2.2.2 Groundwater Resources

Groundwater resources include the water in a saturated subsurface zone and the rocks or
sediments through which this water flows. Groundwater resources serve as a potential pathway
for contaminants to migrate to surface water resources.
Subsurface geology is similar between NWIRP and NAS Dallas. There are three thin water-
bearing zones above the Eagle Ford Shale that together reach to 65 feet below ground level.
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The Eagle Ford Shale in this region is 100 to 200 feet thick and is thought to prevent the
contamination from the shallower water bearing zones from migrating into the deeper aquifers
(Radian International 1999; Tetra Tech 2003; ENSAFE 2001a). All the shallow groundwater at
NWIRP is believed to discharge into surface water bodies, including Mountain Creek Lake
(Radian International 1999).
The 2001 Affected Property Assessment Report for Mountain Creek Lake (ENSAFE 2001a)
describes the geology/hydrogeology as follows:
A layer of sediment is submerged beneath the lake water and covers pre-lake clayey
and silty clay soils. These soils overlie alluvial sequences deposited along the stream
course of Mountain Creek. The fluvial alluvium directly overlies the Cretaceous Eagle
Ford Shale. Groundwater is typically encountered in alluvial deposits. Directly
beneath the lake, the entire alluvial column is likely saturated due to influent lake
water.
Currently, the Trustees do not plan on focusing on groundwater for the assessment. However,
it may be considered as a pathway for contamination for other resources. It is expected that
any contamination associated with groundwater that was subsequently transported to other
resources (e.g., biological or sediment resources) would be accounted for in the assessment of
those resources.
2.2.3 Air and Geologic Resources

Currently, the Trustees are not considering assessment activities for air or geologic resources.
2.2.4 Biological Resources

Biological resources include fish, birds, terrestrial and aquatic plants, benthic organisms,
threatened, endangered, state sensitive species, other legally protected species (Appendix D),
and other living organisms not listed.
Many biological resources use the Mountain Creek Lake system. Species of birds observed by
the public at the Mountain Creek Lake system are reported on ebird.org (eBird 2020) and
include gulls, terns, cormorants, herons, egrets, vultures, osprey, kites, swallows, pigeons,
sandpipers, and more. There are many fish species within the lake that are historically popular
for fishing, including channel catfish, blue catfish, white crappie, flathead catfish, white bass,
largemouth bass, freshwater drum, common carp, sunfish species, and smallmouth bass (Van
Metre et al. 2003). Fish within the lake system have high concentrations of PCBs and dioxins,
which led to fishing bans and consumption advisories (TDH 1996; TDSHS 2010b; TDSHS 2017).
Vegetation is currently composed of emergent plant species. Water hyacinth, an invasive
aquatic plant, has been observed on the lake and subsequently treated to control its spread
(Fox et al. 2017).
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2.2.5 Human/Recreational Use

The Mountain Creek Lake system provides opportunities for recreational activities. The area is
surrounded by neighborhoods, parks, a golf course, a disc golf course, and a public boat ramp.
Additionally, Dallas Baptist University is within walking distance of the lake. The lake is used for
fishing, and many fish species were consumed by anglers (Van Metre et al. 2003). Historically,
TPWD stocked Florida largemouth bass (1980-1994) and red drum (1981) in Mountain Creek
Lake (TPWD 2020b). In 1996, TDH declared that the Mountain Creek Lake system was a
prohibited area for the possession of all fish species in Aquatic Life Order Number 12 (TDH
1996) and TPWD stopped stocking the lake. The possession ban was rescinded in 2010, and it
was replaced with a consumption advisory (ADV-44) that stated all fish species should not be
consumed (TDSHS 2010b). In 2017, the consumption advisory was updated (ADV-59) to advise
limited consumption of specific fish (TDSHS 2017).
3. INJURY ASSESSMENT AND PATHWAY DETERMINATION

APPROACH
This Assessment Plan sets forth assessment studies and activities the Trustees intend to pursue
as part of the NRDAR for the Mountain Creek Lake system. This document focuses primarily on
studies relating to injury assessment (determination and quantification).
During the injury assessment, the Trustees quantify the effects of the release(s) of hazardous
substances on the injured natural resources. For purposes of NRDAR, the Trustees measure the
extent of the injury, estimate the baseline condition and/or baseline services of the injured
natural resource, determine the recoverability of the injured natural resource, and estimate the
reduction in services that resulted from the release(s) of hazardous substances (43 CFR
§ 11.70(c)). As defined in the DOI NRDAR Regulations, baseline means the condition or
conditions that would have existed at the Assessment Area had the releases of the hazardous
substances under investigation not occurred (43 CFR § 11.14(e)). Baseline conditions may be
established based on the review of historical, pre-release data and information, or by control
areas that exhibit similar physical, chemical, and biological conditions as the Assessment Area
and lack exposure to the releases (43 CFR § 11.72).
At this time, the Trustees have determined that further assessment is required for the surface
water resources and biological resources and their services, including human uses (e.g.
recreational activities).
3.1 Temporal
The temporal scope of this assessment will be based on determining injuries to natural
resources and corresponding reductions in natural resource services from the time of the initial
release through the return of the injured resource to baseline conditions. The assessment will
include a review of existing investigation reports and literature to determine when the injury
13 | P a g e
began and the length of the recovery period (the time required to return to baseline). The rate
of recovery will be determined based on data and information concerning remedial and
restoration activities, natural attenuation, and resource recoverability.
3.2 Use of Available Data

The Trustees’ general approach to the assessment is to review the existing data, analyze gaps,
and then undertake additional studies including sampling and data analysis as needed.
3.3 Intent to Perform a Type B Assessment

As part of the assessment planning process, the Trustees must decide whether to conduct a
simplified assessment (Type A) or a comprehensive assessment (Type B). The Type A
procedures, which use minimal field observations and computer models to generate a damage
claim, are limited by the DOI NRDAR Regulations to the assessment of relatively minor, short
duration discharges or releases in coastal or marine environments or in the Great Lakes.
Considering the complexities noted above and other considerations, the Trustees have
determined that the simplified procedures of the Type A assessment are inappropriate for this
NRDAR. The Trustees have concluded that the Type B procedures are appropriate for this
NRDAR based on the Trustees' assessment that (1) the nature of the releases and exposures to
hazardous substances in the Assessment Area are complex, spatially and temporally, and are
not short-term; (2) data that is site-specific and substantial already exists to support this
assessment; and (3) additional data for the Assessment Area can be gathered at a reasonable
cost/in a cost effective manner.
According to the DOI NRDAR Regulations, the Trustees must confirm that at least one of the
natural resources identified as potentially injured in the Preassessment Screen has been
exposed to released hazardous substance before including any Type B methodologies in the
Assessment Plan. The Preassessment Screen identified several resources and their services that
were potentially injured as a result of the releases of hazardous substances from the Facility,
including:
• Recreational uses
• Migratory waterfowl
• Surface water
• Submerged lands and sediments
• Terrestrial organisms
• Benthic organisms
• Groundwater
• Biota
PCB concentrations found in fish tissue confirm the exposure of at least one natural resource to
hazardous substances from the Facility (TDH 1996; TDSHS 2010a; TDSHS 2010b; TDSHS 2017).
Information describing the methods that confirm additional resources have been exposed will
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be described in the sections below under Pathway Determination and Injury Assessment.
3.4 Pathway Determination

Pathway determinations involve identifying the sources of hazardous substances and tracing
the fate and transport of the substances through the environment (e.g., through surface water,
sediments, or food webs). Pathways may be determined by demonstrating the presence of a
hazardous substances in a resource or by using a model (43 CFR §11.63(a)(2)).
Significant investigation into pathways has been conducted in the Assessment Area (ENSAFE
1999; ENSAFE 2001a; Beckley 2016b; Beckley 2016c; Van Metre et al. 2003). Trustees
developed a conceptual model visualizing the pathways for effects on ecological resources
(Figure 3.1) based on these documents.
The primary mechanisms for releases of hazardous substances from the Facility was site
operations, waste disposal, and spills and leaks. Stormwater runoff, historical point-source and
non-point source discharges, and groundwater flow provide transport mechanisms for
hazardous substances into the Mountain Creek Lake system. Possible pathways for ecological
exposure include direct contact with contaminated surface water, sediments, and soil;
ingestion of contaminated sediment or soil during foraging or feeding; indirect contact through
ingestion of contaminated prey species (i.e., bioaccumulation, bioconcentration, and
biomagnification); and/or, direct contact and ingestion of re-suspended contaminated
sediments.
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Figure 3.1 Conceptual model describing the fate of releases from the Facility.
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4. INJURY ASSESSMENT
The Trustees will be evaluating injury associated with aquatic resources and
human/recreational use. The assessment of aquatic resources will include consideration of
sediments, waters, and biota in, or using, the aquatic habitat. Human/recreational use will
consist of the services provided to humans from the Assessment Area.
4.1 Injury Assessment for Aquatic Resources

The Trustees anticipate focusing assessment of aquatic resources on the sediment and fish
tissue data and the pathway for the sediments to affect biological resources. The Trustees will
review data and information generated as part of the RCRA Facility Assessment, the remedial
process (e.g., Corrective Action Orders, Remedial Action Plans, monitoring reports associated
with monitored natural recovery [MNR]), and other relevant literature such as TCEQ
benchmarks, EPA screening values, and published injury thresholds. The Trustees will evaluate
remedial actions including those associated with hot spot removal and MNR. This will include
reports associated with pre- and post-remedial monitoring data, since this data may be used to
assess the likelihood and/or rate of resource recovery. The Trustees will consider peer-
reviewed literature on the harmful effects of contaminated sediments on amphibians, aquatic
mammals, benthic organisms, birds, fish, and reptiles. The Trustees will focus on published
literature describing resource impairment at environmentally relevant concentrations observed
in sediments and fish. The Trustees reserve the right to evaluate any new or relevant data
sources that may inform the injury assessment.
4.1.1 Aquatic Resource Evaluation

Biological resources within the Assessment Area may have been injured by direct contact with
suspended or dissolved chemicals in the water column, direct contact with contaminated
sediments, ingestion of contaminated sediment during foraging or feeding, and/or indirect
contact through ingestion of contaminated prey species, including bioaccumulation. Biological
injuries to aquatic biota may be assessed in amphibians, aquatic mammals, benthic organisms,
birds, fish, and reptiles.
The Trustees will evaluate the concentrations of chemicals in sediments and fish to assess the
degree to which these substances may be causing adverse effects to exposed biological
resources by performing a series of tasks.
Task 1 – Perform screening of chemical contaminants in sediment and fish
The purpose of Task 1 is to identify chemical contaminant concentrations exceeding the most
stringent ecological benchmarks and injury thresholds:
• Identify the highest sediment and fish concentrations for each released chemical;
• Compare the highest chemical concentrations to the lowest and most conservative
17 | P a g e
applicable ecological benchmark or injury thresholds; and

• Develop a database of retained chemical contaminants for analysis.
Task 2 – Assess trends of contaminant data and perform data analysis
The purpose of Task 2 is to identify the spatial extent and temporal patterns of chemical
contaminant concentrations above baseline and determine if quantifiable injuries to biological
resources occurred from exposure to chemical contaminants. The Trustees will use a data
quality objectives approach to perform the data analysis (EPA 2000; EPA 2006a; EPA 2006b; EPA
2006c) to:
• Analyze and apply appropriate statistics on selected data to compare chemical

concentrations in the Assessment Area to baseline concentrations or other
appropriate chemical observations;
• Visualize data using charts, graphs, and/or maps; and
• Describe and document analysis results.
Task 3 – Perform geospatial analysis
The purpose of Task 3 is to determine the geographic and temporal extent of injury or
contamination. Information from Task 1 and Task 2 will be used during this analysis. ArcGIS™
will be employed to perform data interpolation and visualization techniques that can quantify
the geographical extent of injury or contamination. This task may include the following actions:
• Identify data that are appropriate for interpolation and visualization;

• Visualize data using charts, graphs, and/or maps; and/or
• Delineate the number of acres of impacted area by magnitude of contamination or
magnitude of injury.
4.2 Injury Assessment for Human/Recreational Use

The Mountain Creek Lake system provides resources and services enjoyed by people.
Recreational activities associated with the lake include fishing, boating, and bird watching.
The Trustees anticipate using existing data to model losses associated with angler use and
enjoyment. This information could include, but is not limited to, information about limits or
bans on the consumption of fish species; angler survey data, creel data, and fishing license data
collected by TPWD; data collected by the U.S. Census; and fishing data collected by the USGS.
Additional field data collection is not anticipated for this portion of the assessment.
Based on currently available information and the need to quantify injuries, lost angler use is the
only lost recreational use that the Trustees are evaluating at this time. Other losses associated
with passive use (e.g. bird watching, walking, general enjoyment) could be assessed and
addressed in a separate Assessment Plan if the additional assessment is considered cost-
effective (i.e., the cost of the assessment relative to the cost of restoration).
18 | P a g e
5. APPROACH TO DAMAGE DETERMINATION

In the damage determination phase, the Trustees determine the monetary value (damages) of
the injuries to natural resources resulting from the releases of hazardous substances (CERCLA
§§ 107(a)(4)(C), 107(f)(1); 43 CFR § 11.15).
5.1 Aquatic Resource Damage Determination

A common technique that the Trustees may use to determine aquatic resource damages is a
service-to-service scaling approach using the habitat equivalency analysis (HEA) methodology.
HEA is a tool that can be used to generate a common metric (discounted service acre-years
[DSAYs]) to describe service losses due to injury and service gains due to restoration, thereby
providing a way to directly compare the level of injury with the level of restoration. This tool
considers the past and future losses of services provided by a habitat as a result of releases of
hazardous substances. Using a discount factor, service losses are adjusted into a present-day
level of services (NOAA 2006).
Once the above analysis is complete, the Trustees will identify appropriate restoration activities
that will compensate for injured, lost, or destroyed natural resources, then estimate the cost to
implement them (43 CFR § 11.14 (l)).
5.2 Human/Recreational Use Damage Determination

The Trustees will assess the value of the losses to human/recreational use that were incurred as
a result of the releases from the Facility. At a minimum, the Trustees will rely on existing
literature, studies and publicly available data to develop model(s) to evaluate the public’s
willingness to pay and/or the economic value of the resources to the public attributable to the
direct use of the services provided by the natural resources.
The damage determination process will account for reservoir characteristics (e.g., shoreline
miles, public access facilities, fish consumption advisory, etc.) that occur in both the baseline
and release conditions. The Trustees will investigate the appropriateness of various models
(including a recreation demand model) to determine the appropriate model for valuing lost
human/recreational services associated with the injured natural resources.
6. PRELIMINARY ASSESSMENT OF DAMAGES

A preliminary assessment of damages will use information from the Injury Assessment. Since
injury has not yet been fully quantified, the preliminary assessment of damages will be
completed later. Once complete, it will be made available for public review and comment.
7. QUALITY ASSURANCE
Assessments employing Type B methods are required to develop a Quality Assurance Plan
19 | P a g e
(QAP) that adheres to the requirements of the NCP and guidance provided by EPA (43 CFR §
11.31(c)(2)). The purpose of the QAP is to ensure that data are of sufficient quality to be used
for injury assessment and damage determination. The quality assurance procedures described
below are general in nature because the assessment relies primarily on data and information
that already exists. The QAP will be updated and made publicly available prior to the initiation
of any new Trustee-led data collection.
Data sources will be screened to verify that supporting documentation is sufficient to allow for
an evaluation of the reliability and usability of the information. Required information will differ
with data and information types, but may include:
• Sampling methodology, including information on sample locations, environmental

media sampled, and measurement units;
• Chemical analysis, including information on detection limits and methodology
accompanying quality assurance/quality control (QA/QC) data or separate QA/QC
report;
• Raw data or data tabulations (e.g., rather than figures only); and
• Agreement from a governing body that the data collection methods/analysis were
appropriate (e.g., published in a peer reviewed journal; approved for use in the
remedial process).
The Trustees may compile data from multiple sources to assess injury. Quality checks will be
made on all data that is keyed into an electronic format. All data and data sources will be
backed up on external drives or a common network drive. The data and data sources used in
the injury assessment will be stored and maintained by TPWD.
Data may be excluded from consideration if it is determined that appropriate supporting
documentation has not been provided or the available documentation is insufficient. The
Trustees may reference comments made during the remedial process to help make this
determination.
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performing CERCLA response actions on DOD property. The U.S. Navy has appointed the
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its name to DGIC, LLC. TCEQ Corrective Action Order (CAO) No. 31268, TCEQ SWR No.
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Letter dated January 29, 2015; ABMCIC Errata Figures (2A-2, 2A-3, and 2A-4) to be
replaced in the ABM CIC February 5, 2015 Response to TCEQ Comments; ABMCIC
revised Worksheets 3.0, 3.1 and revised Table 1A-1 dated February 24, 2015 in response
to TCEQ comments via e-mails dated February 13 and 17, 2015; ABM CIC response
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Seaton, B. 2014. Subject: American Brownfield (AB) Request to Submit a Revised Sediment
Response Action Plan (Sediment RAP for Cottonwood Bay and Mountain Creek Lake,
Mountain Creek Industrial Center (MCIC), Dallas County, Texas, TCEQ SWR No. 31268,
TCEQ Corrective Action Order (CAO) No. 31268, EPA ID No. TX 6170022770,
CN604095455/RN1014345687. (Letter from Beth Seaton, TCEQ, to Stuart Jones,
American Brownfield MCIC, LLC. Aug. 29, 2014).
Seaton, B. 2019. Subject: Transmittal of Class 2 Corrective Action Order Modification, Dallas
Global Industrial Center (DGIC), LLC, Dallas, Dallas County, Corrective Action Order No.
31268, Industrial Solid Waste Registration No. 31268, EPA Identification No.
TX6170022770RN101434587/CN604095455. Letter from Beth Seaton, TCEQ, to
Nathaniel Hagedorn, Northpoint Development (NPD) Management, LLC. July 2, 2019).
Seaton, B. 2020. Subject: Transmittal of Final Draft Class 1-1 Corrective Action Order
Modification, Dallas Global Industrial Center (DGIC), LLC, Dallas, Dallas County,
Corrective Action Order No. 31268, Industrial Solid Waste Registration No. 31268, EPA
Identification No. TX6170022770; RN101434587; CN604095455. Letter from Beth
Seaton, TCEQ, to Nathaniel Hagedorn, Northpoint Development (NPD) Management,
LLC. May 20, 2020).
Tetra Tech NUS. 2003. Groundwater Compliance Plan. Groundwater Compliance Plan
Application: Naval Air Station Dallas, Dallas, Texas. Comprehensive Long-Term
Environmental Action Navy (Clean) Contract. Contract number: N62467-94-D-0888,
Contract task order: 0052.
Tetra Tech NUS. 2009. Draft Final Mountain Creek Lake Sediment Response Action Plan: Naval
Weapons Industrial Reserve Plant, Dallas, Texas. Rev. 1 June 2009.
Tetra Tech NUS. 2012. Mountain Creek Lake Sediment Sampling Technical Memorandum; Naval
Weapons Industrial Reserve Plant, Dallas, Texas. Revision 1, November 2012.
Texas Commission on Environmental Quality (TCEQ). 2011. Corrective Action Order No. 31268.
Signed Dec. 12, 2011.
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TCEQ. 2012. Subject: Class 1 Corrective Action Order Modification, Mountain Creek Industrial
Center (MCIC), Dallas County, Texas, TCEQ SWR No. 31268, TCEQ Corrective Action
Order No. 31268, EPA ID No. TX6170022770, CN604095455/RN101434587. (Letter to
Stuart A. Jones, American Brownfield MCIC, LLC. October 5, 2012).
TCEQ. 2018. Texas Commission on Environmental Quality Response Action Plan Report. ID No.
31268. March 9, 2018.
Texas Department of Health (TDH). 1996. Aquatic Life Order Number 12. Issued Apr. 25, 1996.
https://dshs.texas.gov/seafood/PDF2/FishConsumptionAdvisoryBaNNews/AL-
12_PR_MountainCRL.pdf (Accessed Oct. 28, 2020).
Texas Department of State Health Services (TDSHS). 2010a. Characterization of potential health
effects associated with consumption of fish from Mountain Creek Lake, Dallas County,
Texas.
http://www.dshs.state.tx.us/WorkArea/linkit.aspx?LinkIdentifier=id&ItemID=85899356
70 (Accessed October 29, 2020).
TDSHS. 2010b. Texas Department of State Health Services Fish and Shellfish Consumption
Advisory, ADV – 44. Issued Oct. 1, 2010.
https://dshs.texas.gov/seafood/PDF2/Active/ADV-44signed.pdf (Accessed Oct. 28,
2020).
TDSHS. 2010c. Texas Department of State Health Services. Aquatic Life Order Number 18.
Issued Oct. 1, 2010.
https://www.dshs.state.tx.us/seafood/PDF2/FishConsumptionAdvisoryBaNNews/AL-
18.pdf (Accessed March 5, 2021).
TDSHS. 2017. Texas Department of State Health Services, Fish and Shellfish Consumption
Advisory, ADV – 59. Issued Jan. 13, 2017.
https://dshs.texas.gov/seafood/PDF2/FishConsumptionAdvisoryBaNNews/MountainCre
ekLakeMap_ConsumptionADV59/ (Accessed Oct. 28, 2020).
Texas Historical Commission. 2000. Texas Historical Sites Atlas. Details for Hensley Field,
Historical Marker — Atlas Number 5113011711.
https://atlas.thc.state.tx.us/Details/5113011711 (Accessed October 14, 2020).
Texas Natural Resource Conservation Commission (TNRCC). 1994. Texas Natural Resource
Conservation Commission; Permit for Industrial Solid Waste Management Site. Naval
Weapons Industrial Reserve Plant, 387, US Navy, Vought Aircraft Company Dallas, Texas.
Permit No. HW-50279. EPA ID No. TX6170022770.
TNRCC. 2001a. Nine Total Maximum Daily Loads for Legacy Pollutants in Streams and a
Reservoir in Dallas and Tarrant Counties: For Segments 0805, 0841, and 0841A.
https://www.tceq.texas.gov/assets/public/waterquality/tmdl/05dalleg/05-
27 | P a g e
dalleg_adopted.pdf (Accessed Oct. 27, 2020).

TNRCC. 2001b. Implementation Plan for Dallas and Tarrant County Legacy Pollutant TMDLs: For
Segments 0805, 0841, and 0841A.
https://www.tceq.texas.gov/assets/public/waterquality/tmdl/05dalleg/05-
dallas_imp.pdf (Accessed Oct. 29, 2020).
Texas Parks and Wildlife Department (TPWD). 1957. Fisheries Investigations and Surveys of
Waters of Region 4-B. Inventory of the Species in Mountain Creek Lake, November 1,
1955 to October 1, 1956. Project No. F4R3. Job No. B-16.
TPWD. 2016. Mountain Creek Reservoir – 2016 Survey Report.
https://tpwd.texas.gov/publications/pwdpubs/lake_survey/pwd_rp_t3200_1343/
(Accessed Oct. 27, 2020).
TPWD. 2020a. Texas Lake Finder – Mountain Creek Lake.
https://tpwd.texas.gov/fishboat/fish/recreational/lakes/mountain_creek/ (Accessed.
Oct. 30, 2020).
TPWD. 2020b. Stocking History for Mountain Creek Lake (Dallas County).
https://tpwd.texas.gov/fishboat/fish/action/stock_bywater.php?WB_code=0513
(Accessed Oct. 30, 2020).
TPWD, TCEQ, GLO, and USFWS. 2000. Preassessment Screen and Determination, Mountain
Creek Lake: Dallas Naval Air Station and Naval Weapons Reserve Plant, Dallas, Texas.
October 5, 2000.
Texas Water Development Board (TWDB). 2020. Water Data for Texas – Mountain Creek Lake.
https://www.waterdatafortexas.org/reservoirs/individual/mountain-creek (Accessed
Oct. 27, 2020).
USA Environment. 2014a. 2014 Sediment Assessment Report; Cottonwood Bay and Mountain
Creek Lake, and Solid Waste Management Units (SWMUs) 35 and 85. June 11, 2014.
USA Environment. 2014b. Draft Sediment Response Action Plan: Mountain Creek Industrial
Center Dallas, Texas – TCEQ SWR No. 31268. October 13, 2014.
USA Environment. 2016. Revised SWMU-35 Sediment Hot Spot Removal Response Action Plan
(RAP), Mountain Creek Industrial Center (MCIC) Dallas, Texas. September 2016.
USA Environment. 2018. SWMU-35 Sediment Hot Spot Removal Response Action Completion
Report (RACR). May 2018.
United States Navy (Navy). 1985. Initial Assessment Study of Naval Air Station Dallas, Texas.
Naval Energy and Environmental Support Activity Port Huenema, CA 93043. NEESA 13-
083.
28 | P a g e
Navy. 2020a. History of the Naval Weapons Industrial Reserve Plant, Dallas, Texas. U.S. Navy
Historic Preservation Office, Cultural Resources Branch.
http://www.voughtaircraft.com/heritage/NWIRP/ (Accessed Oct. 27, 2020).
Navy. 2020b. Naval Facilities Engineering Systems Command, Admin Records Files Search for
Dallas_NAS.
https://www.navfac.navy.mil/products_and_services/ev/products_and_services/env_re
storation/administrative_records.html?p_instln_id=DALLAS_NAS (Accessed Oct. 27,
2020).
Van Metre, P.C, S.A. Jones, J. Bruce Moring, B.J. Mahler, and Jennifer T. Wilson. 2003. Chemical
Quality of Water, Sediment, and Fish in Mountain Creek Lake, Dallas, Texas, 1994-97.
U.S. Geological Survey, Water Resources Investigations Report 03-4082.
https://pubs.usgs.gov/wri/wri034082/pdf/wri03-4082.pdf (Accessed Oct. 27, 2020).
Wilson, Jennifer T. 2002. Chemical Data for Bottom Sediment in Mountain Creek Lake, Dallas,
Texas, 1999–2000. U.S. Geological Survey Open-File Report 02-053.
https://pubs.usgs.gov/of/2002/ofr02053/pdf/ofr02-053.pdf (Accessed Oct. 27, 2020).
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APPENDIX A – SITE HISTORY
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Table 1. Site History.

Year Activity or Document Description
The city of Dallas leases property to the U.S. government for a military base
(Hensley Field, later known as NAS Dallas). The base was expanded several
1928 times over its history (THC 2000).
1929 Mountain Creek Dam construction starts (Crawford 2011).
Mountain Creek Lake dam construction completed. The reservoir was
constructed to provide cooling water for the Dallas Power and Light
1937 Company steam turbine power plant (TPWD 1957).
1939 Mountain Creek Lake opens to fishing (TPWD 1957).
The U.S. government commissions the military base as a Naval Air Reserve
1941 Base (Navy 1985).
As part of the U.S. World War II Industrial Mobilization Program the U.S.
government builds the Naval Weapons Industrial Reserve Plant (NWIRP)
Dallas, an aerospace manufacturing complex. NWIRP initially consisted of
85 buildings and structures on 153 acres. The manufacturing complex
1941 expanded over its history to 314 acres (Hardy 2002).
The Navy changes the official designation of the Naval Air Reserve Base
(formerly known as Hensley Field) to Naval Air Station Dallas (NAS Dallas).
The base was used as a training installation for Navy pilots and Naval Air
1943 Reservists from 1943 – 1993 (Navy 1985).
Mountain Creek Lake fish stocking programs starts (first documented fish
stocking for Mountain Creek Lake). Stocking History for Mountain Creek
1978 Lake (Dallas County) (TPWD 2020b).
The Navy performs an Initial Assessment Study of NAS Dallas to identify and
assess sites posing a potential threat to human health or to the
1985 environment due to past disposal practices (Navy 1985).
The Navy performs a Final Resource Conservation and Recovery Act Facility
Assessment Preliminary Review/Visual Site Inspection (PR/VSI) for 135 Solid
Waste Management Units (SWMUs) and 4 Areas of Concern (AOCs) at NAS
1989 Dallas (Kearney 1989).
The Navy sends a letter to the federal and state natural resource Trustees
identifying Department of Defense (DOD) as the lead agency for performing
CERCLA response actions and identifying currently known releases or
1991 potential releases (Malone 1991).
Dallas forms a formal redevelopment authority with the city of Grand
1993 Prairie and Dallas County (Crawford 2011).
Post-Cold War federal law designates NAS Dallas for closure (Crawford
1993 2011).
Navy pilots and Naval Air Reservists no longer train at NAS Dallas (Crawford
1993 2011).
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TNRCC issues the Navy RCRA Permit No. 50279 authorizing operation of a
hazardous waste storage area and requires the Navy to address offsite
1994 contamination (TNRCC 1994).
The Base Realignment and Closure (BRAC) Clean Up Plan summarizes the
status of NAS Dallas' environmental restoration and compliance programs
and the comprehensive strategy for environmental restoration and
1994 restoration compliance activities (ENSAFE 1995).
The Draft-Final Comprehensive Resource Conservation and Recovery Act
Facility Investigation Work Plan, NAS Dallas, Texas, characterizes any
potential or past releases of hazardous substances into the environment
1994 from facilities identified in the BRAC (ENSAFE 1994).
Mountain Creek Lake fish stocking program ends (last documented fish
1994 stocking for Mountain Creek Lake; TPWD 2020b).
The United States Geological Survey (USGS) collects water, sediment, and
fish to support Mountain Creek Lake Phase 1 and 2 studies from 1994 –
1994 1997 (Van Metre et al. 2003).
Texas Department of Health (TDH) issues a fish possession ban, which
prohibits the possession of any fish from the Mountain Creek Lake (TDH
1996 1996).
The USGS Open-File Report 97-245 reports chemical data for bottom
sediment, lake water, bottom-sediment pore water, and fish in Mountain
1997 Creek Lake, Dallas, Texas, 1994 – 1996 (Jones et al. 1997)
1998 The U.S. government decommissions NAS Dallas (Crawford 2011).
The Navy completes a Final Resource Conservation and Recovery Act
Facility Investigation (RFI) for NWIRP. The RFI finds that historical Navy
operations resulted in unauthorized releases to soil, groundwater, and
sediment, and identified multiple solid waste management units (SWMUs)
1999 and areas of concern (AOCs; ENSAFE 1999).
TPWD, on behalf of the Trustees, notifies the DOD, Navy, Air Force, Army,
Air National Guard, City of Dallas, Texas Utilities, and Northrop Grumman
Industries of its intent to pursue damages for the pollution of Mountain
Creek Lake and requests participation in a cooperative natural resource
2000 damage assessment (NRDA; Pitts 2000).
The NRDA Preassessment Screen and Determination finds sufficient cause
to proceed with a NRDA of Mountain Creek Lake, Cottonwood Bay, NAS,
NWIRP, and associated facilities at Mountain Creek Lake, Dallas, Texas
2000 (TPWD et al. 2000).
The Navy declines to participate in a cooperative NRDA and states that if a
claim for damages is filed, the Department of Justice (DOJ) will represent
2000 the Navy (Munsell 2000).
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The Environmental Protection Agency (EPA) and Texas Commission on
Environmental Quality (TCEQ) approves Nine TMDLs for Legacy Pollutants in
2001 Streams and a Reservoir in Dallas and Tarrant Counties (TNRCC 2001a).
TCEQ develops Implementation Plan, Dallas and Tarrant County Legacy
2001 Pollutant TMDLs (TNRCC 2001b).
The Navy submits the APAR for NWIRP Dallas, Texas, to TCEQ. The APAR
concludes that there are multiple sources of contamination at the site.
These include former degreasers, storage areas, an incinerator, and two
2001 lagoons that receive storm and wastewater. (ENSAFE 2001a).
The Navy submits the Draft Affected Property Assessment Report (APAR)
for Mountain Creek Lake, Dallas, Texas, to TCEQ. The APAR concludes that
the Navy's past operations impacted Mountain Creek Lake sediments
2001 (ENSAFE 2001b).
The Navy develops screening level ecological risk assessment (SLERA) for
2001 Mountain Creek Lake and Cottonwood Bay (ENSAFE 2001c).
The USGS open-file report 02-053 summarizes chemical data for bottom
2002 sediment in Mountain Creek Lake, Dallas, Texas, 1999 – 2000 (Wilson 2002).
The Navy submits Newfield’s Revised Sediment Background Analysis Report
for Mountain Creek Lake to TCEQ. The study confirms that Navy activities
impacted Cottonwood Bay sediments, and impacts to Mountain Creek Lake
sediments are limited to the immediate proximity of two NAS Dallas
outfalls. The study also identifies contaminants of concern (COCs)
attributed to Navy activities, and background values for these COCs were
recommended as protective concentration levels (PCLs) for sediment
2003 (Newfields 2003).
A USGS Water-Resources Investigations Report 03–4082, Chemical Quality
of Water, Sediment, and Fish in Mountain Creek Lake, Dallas, Texas, 1994 –
1997, summarizes the occurrence, trends, and sources of inorganic and
2003 organic contaminants in Mountain Creek Lake (Van Metre et al. 2003).
The Navy submits the Draft Final Mountain Creek Lake Sediment RAP to
TCEQ. The Sediment RAP recommends the dredging and consolidation of
affected sediments from selected PCLE zones and capping sediments in
2009 Cottonwood Bay (Tetra Tech NUS 2009).
The Navy submits a Groundwater RAP and schedule for clean-up to address
groundwater contamination associated with AOC-18 to TCEQ (ENSAFE
2009 2009).
The Texas Department of State Health Services (DSHS) rescinds the fish
possession ban and issues a fish consumption advisory recommending no
consumption of fish from Mountain Creek Lake. (TDSHS 2010b; TDSHS
2010 2010c).
TCEQ approves the Soil Response Action Plan (RAP) dated June 2009,
2011 Groundwater RAP dated June 2009, and Mountain Creek Lake Sediment
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RAP. The Sediment RAP includes wholesale sediment dredging and capping
options (Posnick 2011).
TCEQ issues Corrective Action Order (CAO) No. 31268, Docket No. 2010-
0069-IHW-US, to the Navy as the owner of NWIRP and Cottonwood Bay.
The CAO supersedes RCRA Permit No. 50279 and sets the terms and
conditions by which the Navy conducts remediation of soil, groundwater,
2011 and sediment at NWIRP and off-site (TCEQ 2011).
The Navy performs a sediment sampling investigation to evaluate current
2012 sediment chemical concentrations (Tetra Tech NUS 2012).
The Navy sells NWIRP to American Brownfield Mountain Creek Industrial
Center (ABMCIC). Subsequently, TCEQ issues a Class 1 CAO Modification,
2012 approving the transfer of the CAO from the Navy to ABMCIC (TCEQ 2012).
The United States Army Corps of Engineers (USACE) determines that the
2010 approved Draft Final Sediment RAP sediment dredging and capping
2013 options are not viable for permitting (TCEQ 2018).
TCEQ approves a shallow sediment sampling program to reevaluate the
sediment chemical conditions in relation to ecological risk at Cottonwood
2014 Bay and Mountain Creek Lake (USA Environmental 2014a).
ABMCIC submits a revised Sediment RAP to TCEQ (USA Environment
2014b). The revised Sediment RAP requests modification of the approved
remedy as stipulated in the CAO for removal and off-site disposal of
sediments with elevated PCBs from a portion of SWMU 35, Monitored
Natural Recovery (MNR), for Cottonwood Bay and SWMU 35, and that no
further action is necessary at SWMU 85. TCEQ does not have sufficient data
to support a modification of the CAO. An MNR study is needed to
demonstrate it is a viable alternative for remediating contaminated
sediments. TCEQ does not oppose ABMCIC’s concurrently performing an
MNR study and implementing tasks and subtasks of the CAO and
performing interim removal actions such as PCB sediment hot spot removal
2014 at SWMU 35 (Seaton 2014).
USACE grants permission to complete SWMU 35 hot spot sediment
2014 dredging and dewatering activities (TCEQ 2018).
In March 2015, ABMCIC collects sediment and fish tissue samples from
Cottonwood Bay and Mountain Creek Lake to supplement existing historical
data to evaluate the effectiveness of an MNR remedy. Ramboll Environ
2015 2015).
TCEQ approves Sediment RAP for SWMU 35 PCB hot spot removal (Posnick
2015 2015).
ABMCIC submits a Draft Tier 2 SLERA for Mountain Creek Lake and
2015 Cottonwood Bay to TCEQ (Beckley 2016a).
ABMCIC submits a report to TCEQ titled: Development of Fish Risk-Based
2016 Exposure Limits (RBELS) and Representative Fish Tissue Concentrations for
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Human Health Consumption Pathway Mountain Creek Lake and
Cottonwood Bay. This report addresses deficiencies of the Draft Tier 2
SLERA related to the human health fish consumption pathway (Beckley
2016b).
ABMCIC submits a revised SLERA to TCEQ. The results of the SLERA indicate
that no further action is required to achieve critical ecological PCLs in
Cottonwood Bay or SWMU 85, but that a remedy was required for one
small area of elevated PCB-affected sediments in SWMU 35 in Mountain
2016 Creek Lake (Beckley 2016c).
TPWD, on behalf of the Trustees, provides the Navy and ABMCIC with a
notice of intent to conduct restoration planning for the NWIRP and NAS
Dallas at Mountain Creek Lake in the City of Dallas, Dallas County, Texas,
and an invitation to participate in a cooperative NRDA (Gregory 2016a;
2016 Gregory 2016b).
2016 The Navy declines participation in a cooperative NRDAR (Maculan 2016).
2016 ABMCIC declines participation in a cooperative NRDAR (Mack 2016).
ABMCIC responds to TCEQ comments on the evaluation of the human
health fish consumption pathway for Mountain Creek Lake and Cottonwood
Bay. ABMCIC believes that the issues can be resolved by discussing
2016 remediation options, timeframes, and related issues (Beckley 2016d).
2016 TCEQ approves the revised Tier 2 SLERA (Seaton 2019).
In August 2016, ABMCIC submits the MNR Evaluation Report for
Cottonwood Bay and Mountain Creek Lake to TCEQ. Following the receipt
of TCEQ’s comments in April 2017, ABMCIC submits revised report material
to TCEQ in May 2017. The report outlines multiple lines of evidence
2016 demonstrating the natural recovery process (Ramboll Environ 2016).
ABMCIC submits revised SWMU 35 Sediment Hot Spot Removal RAP to
TCEQ. The interim measure includes dredging and dewatering of affected
2016 sediments from hot spot SWMU 35 (USA Environment 2016).
TCEQ approves revised SWMU 35 Sediment Hot Spot Removal RAP (TCEQ
2017 2018).
DSHS revises Mountain Creek Lake fish consumption advisory to a species-
specific advisory recommending consumption guideline for women of
childbearing age and children <12 and women past childbearing age and
2017 males 12 and older (TDSHS 2017).
ABMCIC submits Draft Sediment RAP to TCEQ. The draft RAP consists of an
MNR response action for Cottonwood Bay and Mountain Creek Lake
2017 (ABMCIC 2017).
ABMCIC submits Final Sediment RAP for Cottonwood Bay, SWMU 35, and
SWMU 85. This Sediment RAP replaces the 2009 Sediment RAP in which
ABMCIC proposes to leave sediments in place and use MNR. Wholesale
2018 dredging and removal would have destroyed existing benthic habitat in
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Cottonwood Bay, resulting in significant disruption of existing ecosystems
that would have taken years to recover. MNR will allow existing habitats to
be preserved and for sediment contaminant concentrations to decrease
over time (ABMCIC 2018).
ABMCIC submits Draft-SWMU-35 Sediment Hot Spot Removal Response
2018 Action Completion Report to TCEQ (USA Environment 2018).
TCEQ provides conditional approval for the Final Sediment RAP for
Cottonwood Bay. The RAP proposes to remediate sediments contaminated
with PCBs in Cottonwood Bay and Mountain Creek Lake through the
implementation of MNR. Final approval of the RAP is contingent upon
Dallas Global Industrial Center’s fulfilling the institutional control
2018 requirements of 30 Tex. Admin. Code §350.94 (Posnick 2018).
TCEQ approves SWMU 35 Sediment Hot Spot Removal Response Action
2018 Completion Report (Posnick 2018b).
TCEQ approves the ABMCIC name change. ABMCIC changed its name to
DGIC, LLC, to be more consistent with the branded name of the facility
2018 (Dallas Global Industrial Center; Meyer 2018).
TCEQ approves and issues Notice of Class 2 Modification in Accordance with
30 Tex. Admin. Code, Sections 39.403 and 305.69(c) for DGIC, LLC, CAO. The
CAO authorizes the revised Sediment RAP referenced in the CAO Class 2
Modification to be replace the previous Sediment RAP. The Class 2
Modification authorizes implementation of MNR of sediments in
2019 Cottonwood Bay and Mountain Creek Lake (Seaton 2019).
The DGIC, LLC, submits the Year 0 RAER to TCEQ. The RAER describes the
Year 0 status of the MNR response action for Cottonwood Bay and
Mountain Creek Lake. The MNR response action objective for Cottonwood
Bay is to demonstrate continued decreases in fish fillet PCB concentrations
over time for those species that continue to exceed the DSHS' HAC value for
PCBs of 0.047 mg/kg (TCEQ 2019). DSHS data from 2008 and 2015 does not
indicate a decrease in PCB concentrations. The mean PCB concentration for
all fish combined from 2008 and 2015 were 0.138 mg/kg and 0.141 mg/kg,
2019 respectively (Ramboll Environmental 2019).
TCEQ issues a Class 1 CAO Modification approving an administrative update
to the CAO to reflect the transfer of fee simple title in the Home Depot
NWIRP parcel to VEREIT/OW Dallas TX, LLC (new buyer). DGIC, LLC, will
2020 remain the named party on the CAO and the RAPs (Seaton 2020).
2020 TCEQ approves the Year 0 RAER (Hatfield 2020).
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APPENDIX B – SUMMARY OF RELEASES
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Table 2. NAS and NWIRP Hazardous Waste Generating Activities/Sources.

Waste Type or Material Source/Activity
Metal plating solutions and rinse water NWIRP Plating Shops
containing magnesium, nickel, titanium,
copper, cadmium, chromium, and zinc
Neutralized acid solutions (sulfuric, nitric, NWIRP Plating Shops
chromic, phosphoric, and hydrofluoric)
Alkaline cleaning solutions NWIRP Plating Shops
Waste petroleum, oil, lubricants, hydraulic NWIRP stormwater runoff, shop floor
oils, solvents, antifreeze, and cleaning washdown water, disposal of wastes to
detergents onsite lagoons and ditches/trenches
Solvents (acetone, methyl ethyl ketone, and NWIRP Bond Shop
isopropanol)
Treated effluent from sewage treatment NWIRP
plant possibly containing hazardous waste
Boiler and cooling tower blowdown NWIRP
Phenolic stripper rinse water NWIRP Aluminum parts stripper shop
Herbicide rinse water NWIRP herbicide formulation
Acetone, acetic acid, isopropyl alcohol, NAS parts cleaning
methyl isobutyl ketone, and chlorinated
solvents
Alodine (contains chromium), butyl cellosolve NAS aircraft and vehicle washing
Batteries and acid, ethylene glycol, Fuels (JP- NAS aircraft and vehicle repairs and
5, AVGAS, JP-4), and oils (engine, hydraulic maintenance
lubricating, cutting)
Epoxy paints and strippers (contain phenols NAS aircraft and vehicle
and methylene chloride), lead, toluene, and painting/thinning/stripping
xylene
Methyl ethyl ketone, PD-680 Type I and II NAS degreasing
(mineral spirits solvent), 1,1,1-
trichloroethane, trichloroethylene,
trichlorotrifluoroethane, toluene, and xylene
Identified and unidentified inert fill material NAS SWMU 1 (The Rubble Landfill - unlined)
as well as old oil drums, waste oil lockers,
waste oils, chlorinated solvents, and possible
PCB-containing debris
PCBs NAS storage of transformers and electrical
distribution equipment including small
capacitors, leaks/spills, and waste drums
Fuels (JP-5, AVGAS, JP-4), PD-680, NAS fire fighter training areas
trichloroethylene, alcohol, and petroleum
waste
Lead NAS indoor firing range, building 34, and
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Waste Type or Material Source/Activity

building 20
Petroleum products and waste, chlorinated NAS above-ground and underground storage
solvents, industrial soaps tanks
Petroleum products NAS fuel Tank Farms
Photographic solutions (Silver) NAS photo processing
Sewer discharge including paint strippers, NAS sanitary sewer system
waste Paints, chlorinated and non-
chlorinated solvents, cleaning compounds,
neutralized battery acid, photo processing
chemicals, and petroleum wastes
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APPENDIX C – CHEMICALS OF POTENTIAL CONCERN
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Table 3. List of chemicals of potential concern (COPC) and basic information describing the chemical.
EPA Substance
CAS ATSDR Toxicological
Count Chemical Name COPC Group 2
Registry Service
Number 1 Profile 4
(SRS) 3
1 Cyanide 57-12-5 Cyano SRS Info Toxicological Info
2 Chlorinated dibenzofurans 5
--- Dioxins and Furans SRS Info Toxicological Info
3 Chlorinated dibenzo-p-dioxins 5
--- Dioxins and Furans SRS Info Toxicological Info
4 Aluminum 7429-90-5 Metal SRS Info Toxicological Info
5 Antimony 7440-36-0 Metal SRS Info Toxicological Info
6 Arsenic 7440-38-2 Metal SRS Info Toxicological Info
7 Barium 7440-39-3 Metal SRS Info Toxicological Info
8 Beryllium 7440-41-7 Metal SRS Info Toxicological Info
9 Cadmium 7440-43-9 Metal SRS Info Toxicological Info
10 Chromium 7440-47-3 Metal SRS Info Toxicological Info
11 Chromium III 16065-83-1 Metal SRS Info Toxicological Info
12 Cobalt 7440-48-4 Metal SRS Info Toxicological Info
13 Copper 7440-50-8 Metal SRS Info Toxicological Info
14 Lead 7439-92-1 Metal SRS Info Toxicological Info
15 Manganese 7439-96-5 Metal SRS Info Toxicological Info
16 Mercury 7439-97-6 Metal SRS Info Toxicological Info
17 Nickel 7440-02-0 Metal SRS Info Toxicological Info
18 Selenium 7782-49-2 Metal SRS Info Toxicological Info
19 Silver 7440-22-4 Metal SRS Info Toxicological Info
20 Thallium 7440-28-0 Metal SRS Info Toxicological Info
1
CAS number is a unique identifier of chemical substances
2
Chemicals of Potential Concern (COPC) group are grouped into categories of similar chemicals.
3
The Substance Registry Service (SRS) is EPA’s authoritative resource for information about chemicals.
4
The Agency for Toxic Substances and Disease Registry (ATSDR) provides toxicological profiles for select hazardous substances.
5
There are nearly 210 chlorinated dibenzo-p-dioxin (CDD) and chlorinated dibenzofuran (CDF) isomers in the environment. The World Health Organization
recognizes 17 CDD and CDF congeners that are known to significantly bioaccumulate and has developed toxic equivalency factors for mammals, birds, and fish
to support ecological risk assessment (EPA 2008). The Trustees will consider the evaluation of 17 CDD and CDF congeners in the injury assessment.
41 | P a g e
EPA Substance
Registry Service
Number 1 Profile 4
(SRS) 3
21 Titanium 7440-32-6 Metal SRS Info ---
22 Vanadium 7440-62-2 Metal SRS Info Toxicological Info
23 Zinc 7440-66-6 Metal SRS Info Toxicological Info
24 1,2-dimethylnapthalene 573-98-8 PAH SRS Info Toxicological Info
25 1,6-dimethylnaphthalene 575-43-9 PAH SRS Info Toxicological Info
26 1-Methyl-9H-fluorene 1730-37-6 PAH SRS Info Toxicological Info
27 1-methylphenanthrene 832-69-9 PAH SRS Info Toxicological Info
28 1-methylpyrene 2381-21-7 PAH SRS Info Toxicological Info
29 2,3,6-trimethylnapthalene 829-26-5 PAH SRS Info Toxicological Info
30 2,6-dimethylnaphthalene 581-42-0 PAH SRS Info Toxicological Info
31 2-ethylnaphthalene 939-27-5 PAH SRS Info Toxicological Info
32 2-methylanthracene 613-12-7 PAH SRS Info Toxicological Info
33 4,5-methylenephenanthrene 203-64-5 PAH SRS Info Toxicological Info
34 4-methylphenol (p-Cresol) 106-44-5 PAH SRS Info Toxicological Info
35 9,10-Anthraquinone 84-65-1 PAH SRS Info Toxicological Info
36 9H-Fluorene 1730-37-6 PAH SRS Info Toxicological Info
37 Acenaphthene 83-32-9 PAH SRS Info Toxicological Info
38 Acenaphthylene 208-96-8 PAH SRS Info Toxicological Info
39 Acridine 260-94-6 PAH SRS Info Toxicological Info
40 Anthracene 120-12-7 PAH SRS Info Toxicological Info
41 Benzo[a]anthracene 56-55-3 PAH SRS Info Toxicological Info
42 Benzo[a]pyrene 50-32-8 PAH SRS Info Toxicological Info
43 Benzo[b]fluoranthene 205-99-2 PAH SRS Info Toxicological Info
44 Benzo[e]pyrene 192-97-2 PAH SRS Info Toxicological Info
45 Benzo[ghi]perylene 191-24-2 PAH SRS Info Toxicological Info
46 Benzo[k]fluoranthene 207-08-9 PAH SRS Info Toxicological Info
47 Carbazole 86-74-8 PAH SRS Info Toxicological Info
42 | P a g e
EPA Substance
Registry Service
Number 1 Profile 4
(SRS) 3
48 Chrysene 218-01-9 PAH SRS Info Toxicological Info
49 Coronene 191-07-1 PAH SRS Info Toxicological Info
50 Dibenzo[a,h]anthracene 53-70-3 PAH SRS Info Toxicological Info
51 Dibenzothiophene 132-65-0 PAH SRS Info Toxicological Info
52 Fluoranthene 206-44-0 PAH SRS Info Toxicological Info
53 Indeno(1,2,3-cd)pyrene 193-39-5 PAH SRS Info Toxicological Info
54 Naphthalene 91-20-3 PAH SRS Info Toxicological Info
55 Perylene 198-55-0 PAH SRS Info Toxicological Info
56 Phenanthrene 85-01-8 PAH SRS Info Toxicological Info
57 Phenanthridine 229-87-8 PAH SRS Info Toxicological Info
58 Phenol 108-95-2 PAH SRS Info Toxicological Info
59 Pyrene 129-00-0 PAH SRS Info Toxicological Info
60 Aroclor 1242 53469-21-9 PCB SRS Info Toxicological Info
63 PCB Congeners 6 --- PCB --- Toxicological Info
64 2,2-Biquinoline 119-91-5 SVOC SRS Info Toxicological Info
65 2-Chloronaphthalene 91-58-7 SVOC SRS Info ---
66 Bis(2-ethylhexyl) phthalate 117-81-7 SVOC SRS Info Toxicological Info
67 Butylbenzyl phthalate 85-68-7 SVOC SRS Info ---
68 Diethyl phthalate 84-66-2 SVOC SRS Info Toxicological Info
6
A polychlorinated biphenyl (PCB) congener is a single well-defined chemical compound in the PCB group (EPA 2020). There are 209 PCB congeners. Most PCBs
were manufactured as mixtures of individual congeners (e.g., Aroclor 1254). The Trustees will consider the sum of all 209 PCB congener concentrations to
derive a Total PCB concentration for the injury assessment if PCB congener analytical data is available. The DSHS utilizes recommendations from NOAA,
McFarland and Clarke, and EPA’s guidance documents for assessing contaminants in fish and shellfish for the Texas Fish Consumption Advisory Program (DSHS
2010). The DSHS selects 43 PCB congeners encompassed by the McFarland and Clark and NOAA articles to derive a Total PCB concentration. The referenced
authors chose to use congeners that were relatively abundant in the environment, were likely to occur in aquatic life, and were most likely – as projected from
structure –activity relationships – to show assessable toxicity.
43 | P a g e
EPA Substance
Registry Service
Number 1 Profile 4
(SRS) 3
69 Dimethyl phthalate 131-11-3 SVOC SRS Info ---
70 Di-n-butyl phthalate 84-74-2 SVOC SRS Info Toxicological Info
71 Di-n-octyl phthalate 117-84-0 SVOC SRS Info Toxicological Info
44 | P a g e
APPENDIX D – RARE, THREATENED, AND ENDANGERED SPECIES
45 | P a g e
Table 4. Rare, threatened, endangered species potentially present in the Assessment Area.
Endangered
Taxon Scientific Name Common Name Species Act Relevant Habitat Description
Listing Status
Habitat includes salt, brackish, and freshwater
Birds Laterallus jamaicensis Black Rail Threatened marshes, pond borders, wet meadows, and grassy
swamps
Potential migrant via plains throughout most of state
Birds Grus americana Whooping Crane Endangered to coast; winters in coastal marshes of Aransas,
Calhoun, and Refugio counties, Texas.
Birds Charadrius melodus Piping Plover Threatened Wintering migrant along the Texas Gulf Coast
Birds Calidris canutus rufa Rufa Red Knot Threatened May travel through during spring and fall migrations
Sternula antillarum Habitat includes rivers, lakes, or other wetlands. Diet
Birds Interior Least Tern Endangered
athalassos includes small fish.
Nest in central Texas mixed Ashe-juniper and oak
Golden-Cheeked
Birds Setophaga chrysoparia Endangered woodlands. They are in Texas from March to July to
Warbler
raise their young.
Clams Truncilla macrodon Texas Fawnsfoot Candidate Endemic to the Brazos and Colorado Rivers
46 | P a g e

Mountain Creek Lake and Hensley Field - Assessment Plan

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Draft Available for Public Comment (May 7, 2021)

NATURAL RESOURCE DAMAGE ASSESSMENT

Mountain Creek Lake: Naval Air Station Dallas

Texas Parks and Wildlife Department

2.2 Affected Natural Resources ............................................................................................... 10

3. INJURY ASSESSMENT AND PATHWAY DETERMINATION APPROACH .............................. 13

4.2 Injury Assessment for Human/Recreational Use ................................................................ 18

LIST OF ACRONYMS AND ABBREVIATIONS

ABMCIC American Brownfields Mountain Creek Industrial Center, LLC

PR/VSI Preliminary Review/Visual Site Inspection

1. INTRODUCTION AND BACKGROUND INFORMATION

1.1 Purpose of the Assessment Plan

1.2 Authority to Conduct a NRDAR

• A discharge of oil or a release of a hazardous substance occurred;

1.3 NRDAR Process Overview

Figure 1.2 Phases of the Natural Resource Damage Assessment Process.

1.4 Invitation to Potentially Responsible Parties for Cooperative Assessment

1.5 Coordination with Other Activities

1.6 Public Participation

1.7 Assessment Timeline

2. DESCRIPTION OF THE ASSESSMENT AREA

2.1 Facility History

2.1.1 Facility Development

2.1.2 Summary of Releases

2.1.3 Confirmation of Exposure

2.2 Affected Natural Resources

2.2.1 Surface Water Resources

2.2.2 Groundwater Resources

2.2.3 Air and Geologic Resources

2.2.4 Biological Resources

2.2.5 Human/Recreational Use

3. INJURY ASSESSMENT AND PATHWAY DETERMINATION

3.2 Use of Available Data

3.3 Intent to Perform a Type B Assessment

3.4 Pathway Determination

4.1 Injury Assessment for Aquatic Resources

4.1.1 Aquatic Resource Evaluation

applicable ecological benchmark or injury thresholds; and

• Analyze and apply appropriate statistics on selected data to compare chemical

• Identify data that are appropriate for interpolation and visualization;

4.2 Injury Assessment for Human/Recreational Use

5. APPROACH TO DAMAGE DETERMINATION

5.1 Aquatic Resource Damage Determination

5.2 Human/Recreational Use Damage Determination

6. PRELIMINARY ASSESSMENT OF DAMAGES

• Sampling methodology, including information on sample locations, environmental

https://pubs.usgs.gov/of/1997/0402/report.pdf (Accessed. Oct. 27, 2020).

dalleg_adopted.pdf (Accessed Oct. 27, 2020).

APPENDIX A – SITE HISTORY

Table 1. Site History.

Year Activity or Document Description

Year Activity or Document Description

Year Activity or Document Description

Year Activity or Document Description

Year Activity or Document Description

APPENDIX B – SUMMARY OF RELEASES

Table 2. NAS and NWIRP Hazardous Waste Generating Activities/Sources.

Waste Type or Material Source/Activity

APPENDIX C – CHEMICALS OF POTENTIAL CONCERN

APPENDIX D – RARE, THREATENED, AND ENDANGERED SPECIES

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